The tax audit report for FY 2025-26 is due on Wednesday 30 September 2026, no extension has been announced, and this year's audit is still a 1961 Act audit under section 44AB even though the section is now numbered 63.
Last verified: 5 September 2026 · Applies to: FY 2025-26 (AY 2026-27) and Tax Year 2026-27
Contents
- The date is 30 September 2026, and no extension has been announced
- Which law governs this audit: the two-year picture
- Who has to get audited
- What actually goes wrong in the last three weeks
- If you miss 30 September
- A dated three-week plan
- Frequently asked questions
- How BVACA can help
The date is 30 September 2026, and no extension has been announced
| Compliance | Due date | Status |
|---|---|---|
| ITR-1 / ITR-2, non-audit | 31 July 2026 | Passed |
| ITR-3 / ITR-4, non-audit business | 31 August 2026 | Passed |
| Tax audit report, Form 3CA or 3CB with Form 3CD | 30 September 2026 | Upcoming |
| ITR, audit cases | 31 October 2026 | Upcoming |
| Form 3CEB, transfer pricing | 31 October 2026 | Upcoming |
| ITR, section 92E transfer pricing cases | 30 November 2026 | Upcoming |
| Belated or revised return | 31 December 2026 | Upcoming |
No CBDT extension has been announced as at 5 September 2026. Plan on the date in the table.
People are expecting one this year for a specific reason, and it is a misreading. Returns that used to fall due on 31 July were filed on 31 August this season, and many taxpayers experienced that as "the department extended it again". It was not an extension. The due dates were rationalised by the Finance Act 2026, which introduced a 31 August slot as a statutory due date. A statutory amendment and a departmental extension order are different things: the first is permanent and applies to the whole class, the second is discretionary, late-arriving and never guaranteed.
One more thing about 30 September 2026: it is also the AGM due date for companies with a 31 March year end, with AOC-4 following 30 days later. The same finance team, the same signed accounts and often the same auditor sit inside both deadlines in one week. See the ROC calendar that collides with the same date and sequence the two deliberately rather than discovering the clash on the 28th.
Which law governs this audit: the two-year picture
This is the part being got backwards this month. The Income-tax Act, 2025 came into force on 1 April 2026 and repealed the Income-tax Act, 1961. But the audit you are filing in September 2026 is for FY 2025-26, a year that ended before the new Act commenced, so it is a 1961 Act audit. Proceedings for periods before 1 April 2026 continue under the 1961 Act.
| FY 2025-26 (AY 2026-27), the audit due now | Tax Year 2026-27, the audit due next year | |
|---|---|---|
| Governing statute | Income-tax Act, 1961 | Income-tax Act, 2025 |
| Audit provision | section 44AB | section 63 |
| Report forms | Form 3CA or 3CB, with Form 3CD | Form 26 |
| Transfer pricing report | Form 3CEB | Form 48 |
| Report due | 30 September 2026 | Specified date = one month before the ITR due date, section 63(5)(a) |
| ITR due, audit cases | 31 October 2026 | 31 October 2027, section 263(1)(c) |
| Year terminology | Previous year and assessment year | Tax year; "assessment year" is no longer a statutory concept |
Two practical consequences follow.
First, do not put "section 63" or "Form 26" on this year's report. The correct citations for the report you are signing this month are section 44AB and Form 3CA or 3CB read with Form 3CD. Writing the new numbers on an old-year report is the characteristic failure of September 2026.
Second, the specified date stops being a fixed calendar date next year. Under section 63(5)(a) the report is due one month before the return due date rather than on a date named in the section. Against the 31 October 2027 return date for audit cases that computes to 30 September 2027, so the answer looks the same, but the mechanism has changed: if a return due date moves, the audit date now moves with it. Change the rule in your compliance calendar, not the date. Our full old-to-new section mapping, the note on which income-tax form replaced which and why assessment year no longer exists cover the rest of the change.
Who has to get audited
| Category | FY 2025-26 threshold (s.44AB; carries into s.63) |
|---|---|
| Business | Turnover / gross receipts above ₹1 crore |
| Business with low cash movement | ₹10 crore where cash receipts and cash payments each stay ≤ 5% of total receipts and payments respectively |
| Profession | Gross receipts above ₹50 lakh |
| Presumptive taxpayers declaring below the presumptive rate | Audit triggered by the shortfall itself, irrespective of turnover |
The higher ₹10 crore cash-mode limit is the one most missed at the trading-firm end of the market: a business that pushes almost all receipts and payments through banking channels does not need an audit until turnover clears ₹10 crore, not ₹1 crore. Test the cash percentages before assuming a client is in audit.
What actually goes wrong in the last three weeks
None of these are exotic. Each takes a day if started on 10 September and a week if started on 26 September.
Bank confirmations
Independent confirmations from every bank and every account, including the ones nobody uses and the one opened for a single EMI. Banks are slow in September because every auditor in India is asking at once, and a branch that answers in two days in June takes ten in the last fortnight. Send these requests before anything else on this list, then do other work while they come back.
Related-party identification
The client identifies related parties and the auditor tests the list, which is almost always incomplete on first pass: people name the group companies and forget the director's HUF, the spouse's proprietorship that supplies packaging, and the firm in which a director's relative is a partner. Ask for the list in writing and signed, then test it against the ledger of every party who is not obviously a trade customer or supplier. Unreported related-party transactions are among the first things a reviewing officer looks for.
Stock and cut-off
Two problems that arrive together. Stock: if no physical verification was done at year end, an alternative procedure has to be designed and documented now, and it cannot be manufactured retrospectively on 29 September. Cut-off: goods despatched before 31 March but invoiced in April, goods received in March but recorded in April. Cut-off errors are usually what break the GST reconciliation below, so fixing them once resolves both.
TDS reconciliation against Form 26AS and AIS
Reconcile TDS deducted and deposited per the books against Form 26AS and AIS, and the credit claimed against the returns filed in Forms 24Q, 26Q, 27Q and 27EQ for the four quarters. Two mismatches recur: an entry deposited under the wrong TAN or section, and a deductee whose PAN was wrong so the credit never reached them. Both are fixed by revising the TDS return, but the correction has to propagate to 26AS before it is useful, which is not a same-day process. Those forms are renumbered to 138, 140, 144 and 143 from the current tax year, and the certificates to Forms 130 and 131, but for FY 2025-26 you reconcile against the old numbering.
GST turnover reconciliation
Reconcile book turnover against GSTR-1 and GSTR-3B for the year. Note the sequencing trap: GSTR-9 and GSTR-9C for FY 2025-26 are not due until 31 December 2026, three months after the audit report, so the audit cannot wait for them. Reconcile against the monthly returns now. Remember too that GSTR-3B Table 3 outward values have been auto-populated and non-editable since the July 2025 tax period, so corrections route through GSTR-1A filed before the corresponding GSTR-3B rather than being adjusted in 3B. Our note on the GSTR-9 and GSTR-9C position for FY 2025-26 sets out the thresholds.
Illustrative example. A trading company has book turnover of ₹12.04 crore for FY 2025-26 against ₹12.31 crore in GSTR-1. The ₹27 lakh gap is credit notes issued in April 2026 against March 2026 invoices, taken in the books as a March reduction but reported in a later GST period. Found on 12 September it is a documented reconciling item and a GSTR-1A correction. Found on 27 September it is a change to a turnover figure in financial statements already circulated for signature.
Loans, deposits and specified sums
Acceptance and repayment of loans, deposits and specified sums otherwise than by the prescribed banking modes is reportable, and it is reported from the ledger rather than from what anyone remembers. The two that get missed are a cash repayment to a director put through as a journal entry, and a loan squared off by contra adjustment rather than by payment. Extract every loan and deposit account and walk the entries.
UDIN, and the acceptance step nobody schedules
Two mechanical steps get left to the last hour and both can fail. The signing chartered accountant generates a UDIN, and the uploaded report must then be accepted by the assessee on the e-filing portal before it counts as furnished. An uploaded but unaccepted report is not a filed report. On 30 September the portal is under national load, the authorised signatory is often travelling, and the DSC on their laptop has frequently expired since last year. Check DSC validity in the second week.
If you miss 30 September
File anyway, immediately. A late report is better than an unfiled one: it stops the exposure growing, it lets the audit-case return be filed, and it is the only fact pattern in which a reasonable-cause explanation is credible.
The consequences run on three tracks. Under section 271B of the 1961 Act (governing FY 2025-26), the penalty is 0.5% of turnover or gross receipts, capped at ₹1,50,000, subject to a reasonable-cause defence under section 273B. The 2025 Act carries the equivalent forward. Reasonable cause is fact-specific — genuine illness of the assessee or the auditor, a serious system failure with contemporaneous evidence, or a partner dispute that stalled the sign-off have historically been accepted; "we were busy" has not.
There is the knock-on to the return. The audit-case ITR is due 31 October 2026 and cannot sensibly be completed without the report, so a slipped audit becomes a late return, with interest running on unpaid tax.
And there is the outer limit: the belated or revised return window for FY 2025-26 closes on 31 December 2026. That is the real cliff edge, and it is why a September slip is recoverable and a December one is not.
A dated three-week plan
Working backwards from Wednesday 30 September 2026, with nothing scheduled on the last day.
| By | Do this |
|---|---|
| Fri 11 Sept | Freeze the trial balance. Send bank confirmation requests. Download Form 26AS and AIS. Check the signatory's DSC validity. |
| Tue 15 Sept | Finish the GST turnover reconciliation. Obtain the signed related-party list and test it against the ledger. |
| Fri 18 Sept | Close stock and cut-off, including the alternative procedure where no year-end count was done. Walk every loan and deposit account. |
| Tue 22 Sept | Finish the TDS reconciliation and file any revising TDS return. Circulate the draft Form 3CD with the reporting positions marked. |
| Fri 25 Sept | Resolve 3CD queries. Obtain the management representation letter. Get the financial statements signed. |
| Mon 28 Sept | Generate the UDIN. Upload Form 3CA or 3CB with Form 3CD. Have the assessee accept it on the portal the same day. |
| Wed 30 Sept | Buffer only. Nothing scheduled here. |
Starting on 20 September rather than 9 September changes the compression, not the order. Bank confirmations still go first, because their turnaround is the one you do not control.
Frequently asked questions
Has the tax audit due date for FY 2025-26 been extended beyond 30 September 2026?
No. As at 5 September 2026 no CBDT extension has been announced and the date stands. The 31 August slot that non-audit business filers used this season was a statutory rationalisation of the due dates by the Finance Act 2026, not a departmental extension, so it is not evidence that one is coming.
Is it section 44AB or section 63 for FY 2025-26?
Section 44AB. The Income-tax Act, 2025 renumbered the tax audit provision to section 63, but it came into force on 1 April 2026 and applies from Tax Year 2026-27. FY 2025-26 ended before commencement and stays under the Income-tax Act, 1961, so this year's report cites section 44AB.
Do I file Form 3CD or the new Form 26 this year?
Form 3CD, with Form 3CA or Form 3CB. Form 26 is the tax audit report under the Income-tax Act, 2025 and applies from Tax Year 2026-27, the audit you file next year. Using Form 26 for FY 2025-26, or citing it in this year's engagement letter, is the common transition error this month.
What is the tax audit due date under the new Act?
Section 63(5)(a) sets the specified date at one month before the return due date rather than at a fixed calendar date. With the audit-case return due 31 October 2027 under section 263(1)(c), that computes to 30 September 2027. The date looks unchanged but now moves with the return date, so calendars should track the rule.
Can I file the audit-case return before the tax audit report is filed?
In practice, no. An audit-case return reports figures the report has to support, so filing first leaves the figures unsupported and the audit obligation outstanding. Sequence the report first, have the assessee accept it on the portal, then file the return by 31 October 2026.
How BVACA can help
We complete tax audits for trading, manufacturing, professional and service businesses across Panchkula, Chandigarh, Mohali and the wider Tricity, and remotely for clients elsewhere in India. Where a file reaches us in the last three weeks of September we work the sequence above rather than starting at the beginning, because bank confirmations and TDS corrections have turnaround times that no amount of effort compresses.
Because FY 2025-26 is the last audit year under the Income-tax Act, 1961, we are also moving clients' compliance calendars to the section 63 and Form 26 position for Tax Year 2026-27, so the change is made once rather than discovered next September. See our audit and assurance work for what a tax audit engagement covers. If a difficult September has you thinking about appointing a different auditor for next year, our note on how to choose a CA firm sets out what to ask before you commit.
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Author box: CA Vijender Singh Bachhal, Managing Partner, Bachhal Vijender & Associates (FRN 028355N), Panchkula. About the firm
Disclaimer: This article is general information current as at 5 September 2026, not advice for a specific situation. Tax and corporate law in India changed materially on 1 April 2026; verify the position before acting. Illustrative examples are not client matters.
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